AN EXAMPLE OF MANAGEMENT PROCEDURE
TO MAINTAIN PART I OF THE INVENTORY OF HAZARDOUS MATERIALS (IHM)
Paragraph 5.2.2 of IMOResolution MEPC.269(68) “2015 GUIDELINES FOR THE DEVELOPMENT OF THE INVENTORY OF HAZARDOUS MATERIALS” following “HONG KONG INTERNATIONAL CONVENTION FOR THE SAFE ANDENVIRONMEN -TALLY SOUND RECYCLING OF SHIPS, 2009”requires that a system be established to maintain the part I of IHM. Following this requirement, here is shown an example of procedure of such system,assuming to designate on shore a person responsible for it. This, however, is not more than an example and another style of system procedure may be established as far as it meets the Convention and the Resolution as mentioned above.
＜ EXAMPLE ＞
MANAGEMENT PROCEDURE
TO MAINTAIN PART I OF THE INVENTORY OF HAZARDOUS MATERIALS (IHM)
Assuming a designated person to maintain the part I of IHM is on shore)
(Revision 0.0)
Revision History of procedure
Rev. No. / Date of Revision / Section No. / Outline of RevisionDefinition/ Abbreviation
HM / : / Hazardous MaterialsIHM / : / Inventory of Hazardous Materials, including the part I, II, III of it.
the Convention / : / Hong Kong International Convention for the Safe andEnvironmentally Sound Recycling of Ships, 2009
the Guidelines / : / IMO Resolution MEPC.269(68), 2015 Guidelines for the Development of the Inventory of Hazardous Materials
the Inventory / : / Referred to the part I of IHM, unless otherwise specified.
DP / : / A designated person as responsible for maintaining and updating the Inventory to meet Par. 5.2.2 of the Guidelines
MD/SDoC / : / Material declaration/ Supplier’s Declaration of Conformity
Table A/B / : / Tables A and B of Appendix 1 of the Guidelines
objects for the Inventory / : / Items requiring to collect information of containing of HM shown in the table A/B by using MD/SDoC, and which are the objects for the part I of IHM.
1Purpose
This “management procedure to maintain the part I of IHM”is established for the purpose of meeting Regulation 5.3 of the Conventionand Par. 5.2.2 of the Guidelinesby means of properly maintaining, during the ship’s operational stage, the part I of IHMdeveloped according to the Convention and the Guidelines[1].
2Policy of Management to Maintain the Inventory
2.1Ship owner designates a person shown in [Supplement 1] as responsible for maintaining and updating the Inventoryfor the ship, and entrust the duty to him on shore.(G/Par. 5.2.1)[2]
2.2Establishment of Management System to Maintain the Inventory
The DP establishes and supervises a system shown in the section 3 in order to ensure that the Inventory on board is properly updated and maintained.(G/Par. 5.2.2)
3Management System to maintain the Inventory
3.1Request of Hazardous Material Information
A person who places an order of structure material, machinery and/or equipment to be installed on board the ship should identify the objects forthe Inventory out of the ordersfollowing the section 4.1, and request a repair yard or suppliers, etc. of those objectsfor MD/SDoC showing information of HM which are contained in the objects.(G/Par. 4.2.2)
3.2Review of Collected Information of HM
A person who receives the deliveries to be on board the ship should ensure that the information of HM is properly collected following the section 4 for the delivered objects.
3.3Development of Revision of the Inventory
The DP or a person assigned by the DP should develop a revision of the Inventory following the section 5 based on the information collected following the sections 3.1 and 3.2, where an object reviewed contains HM.
3.4Review of Revision and Instruction of Updating Inventory
The DP should confirm that the revision of the Inventory is properly developed, should write his signature and otherson it following the section 5.8, and should instruct the shipmaster to update the IHM on board with this revision.
3.5Update ofthe Inventory on Board
The shipmaster should ensure the update of the Inventory on board following the section 6, recognizing that the Inventory is an essential part of the certificate on IHM.(C/App. 3/Note)
3.6Ascertaining the Conformity ofthe Inventory
The DP should follow the section 7 in order to maintain conformity of the Inventory.
4Collection of Information of HM
4.1Items Requiring to Collect MD/SDoC
4.1.1Theitems requiring to collect information of containing of HM shown in the table A/Bare structure material, machinery and equipment which are fixed (i.e., securely fitted with the ship, such as by welding or withbolts, riveted or cemented,and used at their position, including electric cables, gaskets), and applied coating.(G/Par. 2.2, 3.1, 3.2.2, 4.2.2, 4,3,2)
4.1.2For the application of the section 4.1.1, reference should be made to the followings.
① The items which are not fixed, such as portable fire extinguishers, distress flares, lifebuoys, etc., are not required to be listed in the part I of IHM.(G/Par. 2.4, 3.2.3)
② The batteries containing lead acid or other hazardous materials that are fixed in place should be listed in the part I of IHM, but those not fixed, such as consumer batteries and batteries in store are not required to be listed in the part I.(G/Par. 3.2.4)
③ The items, potentially hazardous to the environment and human health at ship recycle facilities,which are shown in Table C of Appendix of the Guidelines, are not required to be listed in the part I of IHM during ship operation, while they are going to be listed in the part II or III when recycling.(G/Par. 3.2.1.3, 3.2.2, App. 1/Table C)
④ Regular consumable goods, potentially containing hazardous materials, which are not integral to a ship and are unlikely to be dismantled or treated at a ship recycling facility, and which are shown in Table D of Appendix of the Guidelines, are not required to be listed in the part I of IHM, while they are going to be listed in the part III when recycling.(G/Par. 3.2.1.4, 3.2.2, App. 1/Table D)
⑤ Materials listed in Table B that are inherent in solid metals or metal alloys, such as steels, aluminium, brasses, bronzes, plating and solders, provided they are used in general construction, such as hull, superstructure, pipes or housings for equipment and machinery, are not required to be listed in the Inventory.(G/Par. 3.3.1)
⑥ Although electrical and electronic equipment is required to be listed in the Inventory, the amount of hazardous materials potentially contained in printed wiring boards (printed circuit boards) installed in the equipment does not need to be reported in the Inventory.(G/Par. 3.3.2)
⑦ Even though the Guidelines does not require the spare parts of the objects for the Inventory to be listed in the part I, theyshouldobtain MD/SDoC in advance, expecting that they are going to be fixed when it is in use.Further, when deliveringa spare partcontaining HM on board, the information should be given to the shipmaster, or a copy of MD should beattached to the spare part,in order for the shipmaster to take a proper action following the section 6.4.(G/Par. 4.1.2, 4.1.3)
4.2Collected MD/SDoC should contain information required by the Par. 6 and 7 of the Guidelines. Examples of them are referred to in Appendix 6 and 7 of the Guidelines.(G/Par. 3.4)
4.3Location on board and approximate quantity of HM needs to be shown in the Inventory, and, therefore, in case where a product consists of plural components located in different places, its MD should be divided correspondingly to the locations of components containing HM.(C/Reg.5.1.1)
4.4A delivery which contains HM excessing the threshold value shown in table A should not be installed on board.(C/Reg. 4.1)[3]
Where it is subject to the followings, it may be on board and should be listed in the Inventory.
① Threshold value1.0% for Asbestos may be applied instead of 0.1% not later than 5 years after the entry into force of the Convention, and, in that case, should be recorded in the Inventory and, if available, the MD. 0.1% need not be retroactively applied.(G /App. 1/Table A)
② A delivery which contains Hydrochlorofluorocarbons(HCFCs) and be installed on board before 1st January 2020 may be permitted.(G /App. 3/Par. 3.2.1)
4.5Revised threshold values of Tables A/B should be used for a revision of the Inventoryto be developed after the adoption of revised values,but need not be retroactively applied.(G/Par. 3.5)
5Development of Revision of the Inventory[4],[5]
5.1If, amongthe objects forthe Inventoryreviewed following the section 4, there is an object containing HM of Tables A/B, a revision of the Inventory should be developed. Especially where new installation, modification, repair, exchange, removal, or alteration of location etc. of structure, machinery and/or equipment, renewal of coating, change of flag,owner or operator is undertaken, attention should be paid so that a proper revision of the Inventory may be made.(C/Reg. 5.3, 10.1.3,G/Par. 4.3)
5.2Wheremachinery,equipment, coating, etc. is exchanged/ renewed with an identical part or coating, update of their inventory is not required.(G/Par. 4.3.2)
5.3The item removed out of board should be clearly specified in such manner that a cross line is put on the removed item, or that the item is deleted out of the Inventoryproviding a separate list of removed items.(G/Par. 5.2.3, App. 2)
5.4A revision of the Inventoryshould be developed following examples in Appendix 2 and 3 of the Guidelines based on the MD showing the information of HM of Tables A/B regardless of development method (G/Par. 4.1 or 4.2) of the initial version of the Inventory.(G/Par. 3.4, 4.1.2～4.1.4, 4.2.2)
5.5In order to show location of HM, names of location which are indicated in General Arrangement, etc. should be used, and in case there is a list of location when initially developedthe IHM, this location list should be utilized.(G/Par. 4.6)
5.6Standard unit to show the approximate quantity of hazardous materials should be kg, unless other units (e.g. m3 for materials of liquid or gases, m2 for materials used in floors or walls) are considered more appropriate. An approximate quantity should be rounded up to at least two significant figures.(G/Par. 4.7)
5.7Same items to be installed may be listed together in the Inventory with general location, but, their location should be as small as they can be identified.(G/Par. 3.2.5/App. 3)
5.8Revision of the Inventory should include date of revision,summary of change/ deletion of items, and signature of DP.(G/Par. 5.2.3)
5.9A copy of the Inventory should be kept on shore.
6Update of the Inventory on Board
6.1Shipmaster should confirm with DP that, for all the items to be delivered on board, revision of the Inventory is properly developed based on the investigation following the section 4.1.
6.2Shipmaster should recognize that the Inventory on board is an essential supplement of the Conventional Certificate on IHM, and should replace the Inventory with its revision immediately after receiving the revision from DP, and maintain IHM up-to-dateat all times.(C/Reg. 5.3)
6.3Shipmaster should undergo a renewal survey and update the supplement of the Certificate, and should reportit to DP.(C/Reg. 10.1.2, G/Par. 4.3.2, Par. 5.2.4)
6.4Where,based on the information given or MD collected following the section 4.1.2⑦, a spare partcontaining HM is fixed on board, the shipmaster should request DP to revise the Inventory and take a necessary action.
7Continuity of Conformity of the Inventory
7.1In case where alteration, exchange or significant repair is made on the structure, equipment, system, fitting, location or material of ship, DP should instruct the shipmaster to undergo an additional survey if necessary and renewthe supplement of Certificate in order to maintain the compliance with the Convention.(C/Reg10.1.3, G/Par. 4.3.2, 5.2.4)
7.2In case where alteration of ship leads to complicated revision of the Inventory, it is recommended to undergo a review of the revision of the Inventory and its supplementary information prior to the additional survey.
7.3DP should confirm on the occasion of internal audit of the ship that the Inventory on board is properly updated with revisions and is consistent with the current condition of HM on board, further should confirm that the Inventory on board coincides with its copy kept on shore, and should make a record of the audit.(G/Par. 5.2)
7.4Where DP is going to be changed in association with a change of flag/shipowner or a sale/recycle of ship, etc., DP should transfer to a new ship owner/ DP the latest version of the Inventoryand its supplementary information (MD/SDoC, etc.).And, further, heshould maintain them so that they may be shown to an inspector on the occasion of survey of flag or port state.(G/Par. 4.3.3, 5.2.4)
[Supplement 1] Designation of person responsible for maintaining and updating the Inventory
The owner of the ship mentioned below designates a person shown below as DP (person responsible for maintaining and updating the part I of IHM of the ship)[6]。DP / Name of Company and department DP belongs to
Name of DP
Contact
Ship concerned / Name of ship
IMO Number
Name of shipowner
[Supplement 2] Example of information list[7] to develop a revision of the Inventory relating to the works done at repair yard
2-1 List of delivery and dismantlement relating to the works
No. / Work name / Contractor of work / Delivery/ Dismantlement / No. / Supplier of delivery1 / BWMS installation / BWMS manufacturer / Filter / 1 / Filter manufacturer
2 / Disinfection appliance / 1 / BWMS manufacturer
3 / Control panel / 2 / BWMS manufacturer
4 / Repair yard / a set of Piping / Gasket manufacturer
5 / Electric cables / E/cable manufacturer
6 / Compound for cable penetration / Compound manufacturer
7 / Maintenance of piping / Repair yard / Dismantled gasket / Gasket manufacturer
8 / Installed gasket / Gasket manufacturer
2-2 Collected MD List
No. / Supplier / Product / Amount / HM(Yes/No) / IHM No. / MD No. / Remarks1
[1]The regulations/paragraphs relevant to the maintenance of IHM are shown in [Supplement 3].
[2]This shows the relevant regulation/paragraph of the Convention or Guidelines, abbreviating “Convention” to “C” and “Guidelines” to “G”.
[3]Where Asbestos is present on board and is listed in the initial version of the Inventory, it is recommended to followMSC/Circ.1045 “GUIDELINES FOR MAINTENANCE AND MONITORING OF ON-BOARD MATERIALS CONTAINING ASBESTOS” for the treatment of it. Where, further, Asbestos which is prohibited to install on board after 2002/7/1 or 2011/1/1 is by mistake installed on board, it should be removed out of ship followingMSC.1/Circ.1374 “INFORMATION ON PROHIBITION OF THE USE OF ASBESTOS ON BOARD SHIPS”.
[4] IHM can be developed utilizing the application in URL referring to “PrimeShip-GREEN/SRM”.
[5]It is recommended to obtain HM information and make a record referring to [Supplement 2] when doing kinds of works at repair yards.
[6]It is recommended to attach a statement of shipowner with his signature/ company stamp stating that he designated the DP.
[7]Purchase List and Collected MD List are automatically generated when inputting data in the application, PrimeShip-GREEN/SRM.